From: Wayne Jervis
Sent: December 1, 2006
Subject: File No. SR-Amex-2006-106

Dear Sirs,

I am a professional money manager and I would like to encourage the SEC to push ahead with penny increment quotes for exchange traded options.

There are several inequities in the options markets which serve the broker community and disadvantage the investor community:

1) no other quoted security has the same %-of-security-price spread between bid and ask prices. These spreads can reach up to $0.20 or more per common-share-equivalent. Common stock spreads have compressed dramatically with the use of penny increment quotes.
2) no other security has the same %-of-security-price commission amount.
3) there is an asymmetry of information between the investor and the market makers, as there is no ability for investors to see the depth of quotes behind the bid and offered securities. This is not the case with listed stocks.
4) options have additional commissions that must be paid to settle exercised contracts, while common stocks only settle once per transaction.

As a result of these inequities and inefficiencies, I strongly believe that the SEC should push ahead with penny quoting to help level the playing field for options investors. I would encourage the SEC to look at leaders in this effort, like Interactive Brokers, as an indication that the SEC should push ahead more aggressively.

I would like to add that brokers have complained at every step along the way to improve investor inequities: decimization of common stocks, TRAC bond quotes, and now listed options. And yet there have been no tangible negative repercussions from these investor-friendly actions.


Wayne Jervis
Managing Member of the General Partner
Jervis Alternative Asset Management Co. (JAAMCO), LP
One Landmark Square, Suite 315
Stamford, CT 06901